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Ms. Rebecca H. Ewing

Acting Executive Secretary

United States Department of the Treasury

C/O e Offi ce of Financial Education, and

Financial Literacy and Education Commission

September 19, 2010

Via E-mail:[email protected]

Comments of PaperChain and Free Community Paper Industry

on the Draft National Strategy for Financial Literacy

PaperChain1 on behalf of its Member Associations2 and the united Free Community Paper Industry, of-

fers the following Comments relating to the Draft National Strategy for Financial Literacy in response tothe Request for Comments issued by Department of the Treasury. As a core function of their collective

enterprise, our hometown publishers actively promote and engage the literacy needs of their diverse com-

munities across America. Literacy, itself, is the fundamental building block of Financial Literacy.4

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2 The member associations of PaperChain are: Association of Free Community Papers (AFCP), Independent Free Papers

of America (IFPA), Community Papers of New England (CPNE), Mid-Atlantic Community Papers Association (MACPA),

Midwest Free Community Papers (MFCP), Pacific Northwest Association of Want Ad Newspapers (PNAWAN), Southeastern

vert s ng u s ers ssoc at on , out western ssoc at on o ommun ty u cat ons , ommun ty a-

pers o n ana an no s , ommun ty apers o or a , ommun ty apers o c gan , scons n

Community Papers (WCP), Texas Community Newspaper Association (TCNA), Minnesota Free Paper Association (MFPA),

Community Papers of Ohio and West Virginia (CPOWV), Free Community Papers of New York (FCPNY).

3 Comment Request for the Financial Literacy and Education Commission on the Draft National Strategy, Entitled National

trategy or nanc a teracy , e era egister, o . , o. , r ay, eptem er , , otices.


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PaperChain applauds the tireless work of the Financial Literacy and Education Commission (FLEC),

and proudly endorses the overriding objectives it is tasked to accomplish. As the Commission notes, this

important work began years before our Nations most recent near economic collapse, dubbed by many

as e Great Recession. No shortage of scholars, economists and journalists have duly noted that sig-

nificant disparities in the financial literacy of our citizens were at least a mitigating factor leading to that

crisis, and we share the hope of many that the critical work ahead will help to prevent future economic

meltdowns.

PaperChain champions the Vision, Mission and Goals detailed in the working Draft of the National Strat-

egy for Financial Literacy. We take keen interest in the first explicit Goal, Increase Awareness of and Ac-

cess to Financial Education, as well as the multiple mentions of collaboration and partnerships from thenational down to the most local, community-based level. We are confident that our industry can deliver

critical and unique capabilities to specific objectives set forth in Goal 1. At the same time, PaperChain

also welcomes the opportunity to serve as a key partner across action areas, and as bridge-builder across

macro and micro geographic divides.

National Media Campaign

We unequivocally embrace the Draft Strategys Vision of sustained financial well-being for all individu-

als and families in the U.S. Our publishers operate on the front lines of the economy, providing the glue

that bonds neighbors and the merchants on Main Street. We share a singular perspective on the condition

of truly local commerce, and we can attest that our collective financial well-being is inextricably linked.

Families, and the dependent business community, have together taken a long, hard look at economic les-

4 Financial Literacy assumes, and is predicated on the core competencies of actual Literacy. A basic and enduring standard

for literacy in most societies is the ability to read a newspaper. The United Nations Educational, Scientific and Cultural Or-

ganization (UNESCO) defines literacy as the ability to identify, understand, interpret, create, communicate, compute and

use printed and written materials associated with varying contexts. Literacy involves a continuum of learning in enabling

individuals to achieve their goals, to develop their knowledge and potential, and to participate fully in their community

and wider society.

5 The Draft National Strategy that we now offer Comment on, is the product of a continuing series of painstaking activities

that date back to the establishment, by Act of Congress, of the Financial Literacy and Education Commission (FLEC) in

2003.

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sons learned from the current financial crisis. In order that lessons sink in, and also that collective amnesia

does not, the aim of seeking:

to foster a culture in which households take periodic stock of their financial situations, individuals

seek information and ask questions before entering into financial transactions, and everyone has

the information and tools needed to help manage debt, save to meet their financial goals, and plan

for secure financial futures6

is paramount to the long-term sustainability of our inter-dependent local and national economies. Com-

merce cannot thrive without able and informed consumers, and a prosperous Nation depends on that

dynamic harmony.

Cultivating a national habit of taking periodic stock of their financial situations will presumably require

an established baseline quantifying both basic knowledge and how it is practiced. From there, the next

critical steps of instilling both an awareness of resources, and the outcome-focused awareness of the need

to actually access these resources, become paramount. None of this can be achieved, however, without

extensive, repetitive and ultimately effective public outreach. e Commission has considered this funda-

mental component of execution, and seeks to: Promote a national media campaign to raise awareness on

financial literacy, including the use of venues and technologies to reach people where they are.7

PaperChain strongly agrees that a national media campaign will be vital to the National Strategy. A

multitude of options exist across traditional and emerging platforms, and we envision the Commission

thoughtfully adopting a strategic blend of so-called old and new media in its ultimate campaign. All of

the best efforts, from identifying at-risk groups to developing ideal curricula, simply cannot achieve full

potential if the intended audience is not reached. e Commission must carefully evaluate the possibili-

ties presented by innovative technologies to reach people,8 but also maintain constant focus on the most

basic need to reach people where they are. At the end of the day, people come home, and they can still be

found most reliably at their residence.

6 Draft National Strategy for Financial Literacy, September 3, 2010, at 6.

7 Draft Strategy t 7.

8 Why and How: Background Report - Developing the 2010 National Strategy, Financial Literacy and Education Commis-

ion, August 2010, at 5.

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Partnerships

PaperChain welcomes the opportunity to partner with the Commission and all stake-holders in the

execution of the National Strategy for Financial Literacy. e need for collaboration and partnerships is

expressed across the range of objectives relating to specific goals. Ultimately, such dynamic partnering

and close coordination will need to occur effectively from the national down to the most local, commu-

nity level. e very Mission of the National Strategy depends on successful teamwork between all stake-

holders. PaperChain, our member associations and our publishers bring a wealth of experience to the

table. PaperChain has proudly served as national partner to the March of Dimes Foundation, successfully

coordinating numerous campaigns over more than five years, working closely with our associations and

publishers.

Our sixteen member state, regional and national Associations each have vast and wide-ranging histories

of success serving as critical partners with non-profit and government entities from municipal to state,

up to the national level. At the same time, our strongest and most enduring bonds are truly grass-roots.

Our hometown publishers are based on Main Street, and bring generations of active community service

expertise and relationships. is is where the rubber meets the road, and together we can help to bring the

National Strategy from an idea formulated in Washington, D.C. to a reality in the communities that make

us America.

Implementation

e Commission asks for specific examples of how organizations would implement the National Strat-

egy.10 PaperChain, carefully coordinating with our sixteen member state, regional and national Associa-

tions, will guide a seamless, national media campaign through 2,673 hometown publications reaching

9 Most recently, MACPA partnered with the U.S. Census Bureau in efforts based in the Mid-Atlantic region, and each of

our member associations has their own laundry list to share. This sampling, from WCP, of their partnerships throughout

Wisconsin are reflective of our organizations: Rawhide Ranch for Boys, securing unwanted vehicles for over 35 years;

Badger Camp for mentally handicapped citizens; Camp Hope a respite for Cancer siblings; the Governors Blue Ribbon

Commission for Drug Prevention - a state-level partner of the National effort, Drug Free America, along with, locally, the

Wisconsin Alliance for Youth; Wisconsin Public Radio; Wisconsin Y2K Commission; Wisconsin Consumer Protection;

and Wisconsin DNR, among others.

10 Request for Comment at No. 6.

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65,187, 292 families where they are. at is to say, at their homes.11 Taking direction from the Com-

mission, and working closely with partner Agencies and stake-holders, we will ensure delivery and raise

measurable awareness of the campaigns message. is will be achieved with equal precision on national

themes as well as any regionalized or hyper localized targeting that might involve distinct messaging, and

correspondingly, geographic or demographically-targeted delivery.

e Commission will be statistically assured that this aspect of execution of the National Strategy will

achieve 97.1% receivership and 76.9% readership in the vast and diverse tapestry of communities served

by our hometown publishers. We understand that future messaging for the anticipated national media

campaign has yet to be formulated, however we would like to offer a possible suggestion that might help

in quantifying a national baseline in levels of financial literacy, as well as the potential pre-awareness of

the need to access existing resources and those under formulation. Our idea is a Financial Literacy Quizcampaign, based on a rotating set of basic but essential financial literacy concepts, and should include calls

to action and outreach contact information.

PaperChain would also help to orchestrate, in conjunction with our sixteen member free community

paper associations, collaboration between all partners and stake-holders, from the national down to the

community-based levels. At the most basic level, this would involve the dissemination of public service

announcements for publication in print and online. More can, and will need to be done, and our publish-

ers are perfectly positioned and experienced with multifaceted outreach in their respective communities.

We, as an industry, are open to all opportunities and suggestions, and offer our hometown facilities as sites

for disseminating collateral materials and other engagement, and volunteer for peer to peer and other

dynamic forms of outreach.

11 One statistic that merits the consideration of the Commission is the comparison of local readerships: Over two-thirds of

our readers do not subscribe to a daily newspaper.

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In conclusion, PaperChain, on behalf of the united free community paper industry, offers our full support

for the Vision, Mission and Goals of the Draft National Strategy for Financial Literacy. We back that sup-port with the pledge to provide incomparable performance in the execution of the national media cam-

paign. Further, we welcome any and all opportunities to partner with the Commission and those organiza-

tions likewise engaged in the effective implementation of the National Strategy.

Respectfully Submitted,

Brian Gay

Chairman, PaperChain

Executive Director, Midwest Free Community Papers

[email protected]

19-341-4352

On Behalf of the Member Associations of PaperChain:

Association of Free Community Papers

Mid-Atlantic Community Papers AssociationIndependent Free Papers of America

Community Papers of New England

Midwest Free Community Papers

Pacific Northwest Association of Want Ad Newspapers

Southeastern Advertising Publishers Association

Southwestern Association of Community Publications

Community Papers of Indiana and Illinois

Community Papers of Florida

Community Papers of Michigan

Wisconsin Community Papers

Texas Community Newspaper Association

Minnesota Free Paper Association

Community Papers of Ohio and West Virginia

Free Community Papers of New York

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